A board of education serving as a review panel in a teacher termination matter need not review all of the evidence presented to the independent hearing officer, according to the Supreme Court of Wyoming.

After the Lincoln County Board of Education voted to accept the recommendation of the hearing officer that Darryl Wadsworth be terminated for insubordination, Wadsworth appealed the decision, claiming that the board’s failure to independently review the entire evidentiary record before making its decision violated his due process rights and Wyoming’s administrative procedure act.

The Wyoming Supreme Court rejected the teacher’s argument that all board members needed to be present for the entire hearing, holding that due process is satisfied as long as the deciding officials understand and consider the evidence before rendering a decision. Rather than focus on strict procedural rules, the court noted that administrative procedures exist only to ensure that an administrative hearing is conducted in a fair, open and impartial manner by unbiased officials. Board members were entitled to rely upon the hearing officers and other members in arriving at its decision.